Legal Opinion
William K. Carpenter and Frances K. Carpenter v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided October 11, 1963No. 14211PublishedCited by 27 opinions
1Opinion of the Court
WILLIAM F. SMITH, Circuit Judge.
The petitioner William K. Carpenter, joined by his wife Frances K. Carpenter, 1 challenges as erroneous the Tax Court’s decision that interest prepayments on loans made against an annuity policy were not deductible from gross income under § 163(a) of the Internal Revenue Code of 1954, 26 U.S.C. 1954 ed. § 163 (a). The decision of the Supreme Court in Knetsch v. United States, 364 U.S. 361, 81 S.Ct. 132, 5 L.Ed.2d 128 (1960), and that of this Court in Weller v. C. I. R., 3 Cir., 270 F.2d 294 (1959), cert. den. 364 U.S. 908, 81 S.Ct. 269, 5 L.Ed.2d 223 (1960),…
2Cases cited13 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945
8 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Davis v. CommissionerUnited States Tax Court · 1976
- United States v. Cornelius W. SullivanCourt of Appeals for the Third Circuit · 1964
- Karl F. Knetsch and Eva Fay Knetsch v. The United StatesUnited States Court of Claims · 1965
- Diamond Bros. Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1963
- Foresun, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1965
22 more not listed; retrieve them via the Exa API.